Thursday, January 20, 2022

Armed Security at Chemical Facilities – Part 2

Back in 2008 I looked at the issue of security guards at chemical facilities that would be covered under the then new Chemical Facility Anti-Terrorism Standards (CFATS) program. Then in 2009, once the CFATS Risk-Based Performance Standard guidance document was published, I specifically looked at the issue of armed guards at CFATS facilities. In that later piece, after noting that there is no CFATS requirement for armed guards, I opined that:

“The bottom line is that if a toxic release COI is present in large enough volumes to present a threat to a relatively large off-site population, an armed response is going to be necessary to prevent a terrorist attack aimed at that COI. If the response force is on-site, it must be armed. If the response force is off-site, it may be necessary to have an on-site security force that is armed to delay the potential attack long enough for the response force to arrive and defeat the attackers.”

My analysis that led to that conclusion, I think remains true today. But does that mean that facilities without a large ‘toxic release COI’ inventory have no need for an armed security force? That is not quite so clear, in my opinion. There is an increased, site-specific, risk associated with the discharge of a firearm at a facility where chemicals are manufactured, used, or stored, so clearly, firearm discharges are something to be avoided. But does avoidance of those discharges prevent the employment of armed guards?

If management decides that there is no conceivable situation where an armed response would be justified at the facility, then the choice is clear, there is absolutely no need for armed guards. Once, however, the decision is made that there are situations where an armed response would be justified, then an armed security force is an option that must be considered. But, one thing must be clearly understood, if the facility does not employ an armed security force, and the use of force becomes necessary, the facility has no option but to use local law enforcement as the tool to employ the use of force. At that point, facility management totally looses control over the use of firearms at the facility. They will have no control over:

• The types of weapons and ammunition that may be employed,

• Restrictions on in which areas of the facility weapons may be employed, or

• The training of the armed personnel on the hazards associated with the employment of firearms at the facility.

If facility management is willing to lose that level of control, then there is no need to consider the use of an armed security force. And an armed security force is more expensive, both in the direct cost to employ them and in the additional training costs necessary to maintain an adequate level of control to reduce the risks associated with weapons discharges. If, however, maintaining some level of control, at least in the early stages of an incident, is of importance, then management is going to have to consider the option of employing an armed security force.

1 comment:

Laurie Thomas said...

Hi Patrick, great post. Law enforcement agencies always have use of force policies and accompanying training. A facility that decides to employ armed personnel needs to have this policy and ensure that there is appropriate training. The liability issues in this area are horrendous. I have performed audits on marine terminals who employ armed personnel and I have asked to see their use of force policy. The facility says, "We don't have one, I think the guard force company might." What! And if the facility relies on local LE, they should have ALREADY had LE in to familiarize the officers with the facility, its operations, and its hazards. Most LE don't understand the term intrinsically safe, for example. If it matters to you, tell them.

/* Use this with templates/template-twocol.html */